All ATM transactions within the UK are carried out through the Link Interchange Network Ltd (known as ‘LINK’). The purpose of the LINK network is to enable customers of member banks and building societies to obtain funds and account services from their own bank or any another bank or building society. Originally all members of LINK were banks and building societies but non-financial institutions have now been admitted. Non financial members are known as independent ATM deployers (‘IADs’). Under the LINK rules each member is allowed to charge either i) the customer or ii) the counter-party bank. Generally, the IADs charge the customer while the banks and building societies generally charge the counter-party bank. All these charges are settled through the LINK system.

As well as enabling inter-bank ATM transactions to take place, LINK also provides a settlement service. At the end of each working day the LINK system calculates the debtor/creditor relationship of each member vis a vis the other members in respect of the ATM transactions that have taken place that day. It then informs the Bank of England to adjust the member’s accounts accordingly. Because LINK is now an integral part of the banking system providing the switching and settlement services which transfer funds between banks and their customers and between LINK members we accept that the supply to its members falls within the exemption at item 1.

Increasingly there are now other players in the ATM market too. It is not uncommon for different parties to be involved in the provision, siting, installation, filling, maintenance, and cash management of ATMs and it is likely that each party will make a charge for its services.